Bank Secrecy Act Compliance. The Bank is in compliance in all material respects with the provisions of the Bank Secrecy Act of 1970, as amended (the “Bank Secrecy Act”), and all regulations promulgated thereunder, including, but not limited to, those provisions that address suspicious activity reports and compliance programs, and all applicable requirements of the Office of Foreign Assets Control. Without limiting the foregoing, the Bank has implemented a Bank Secrecy Act compliance program that adequately covers in all material respects all of the required program elements as required by 12 C.F.R. § 326.8.
Bank Secrecy Act Compliance. Target Bank is in compliance in all material respects with the provisions of the Bank Secrecy Act of 1970, as amended (the “Bank Secrecy Act”), and all regulations promulgated thereunder including, but not limited to, those provisions of the Bank Secrecy Act that address suspicious activity reports and compliance programs. Target Bank has implemented a Bank Secrecy Act compliance program that adequately covers all of the required program elements as required by 12 C.F.R. §21.21.
Bank Secrecy Act Compliance. The Neighbors Entities are in compliance in all material respects with the provisions of the Bank Secrecy Act of 1970, as amended (the “Bank Secrecy Act”), and all regulations promulgated thereunder including, but not limited to, those provisions of the Bank Secrecy Act that address suspicious activity reports and compliance programs. The Neighbors Entities have implemented a Bank Secrecy Act compliance program that adequately covers all of the required program elements as required by 12 C.F.R. §21.21.
Bank Secrecy Act Compliance. Company will reasonably cooperate with Bank, as mutually agreed by the Parties, in the implementation of Bank’s anti-money laundering and anti-terrorism financing compliance program (as modified from time to time, the “AML Program”) in accordance with Applicable Law, including in connection with Bank’s implementation of such commercially reasonable policies and procedures, and modifications to the Program, that may be required by Applicable Law. Company will reasonably cooperate with Bank, as mutually agreed by the Parties, in the implementation of measures to allow Bank to verify the identity of all T-Mobile Customers and prospective T-Mobile Customers consistent with Applicable Law.
Bank Secrecy Act Compliance. In the event that the Gift Card Program qualifies as a “prepaid program” (as defined in the Bank Secrecy Act), Xxxxxxxx agrees that it shall serve as the “provider of prepaid access” (as defined in the Bank Secrecy Act) and comply with all of the requirements of a provider of prepaid access under the Bank Secrecy Act, including, without limitation, the requirement to register as a money services business with the Financial Crimes Enforcement Network of the United States Department of the Treasury and identify the prepaid programs for which it is serving as the provider of prepaid access. Merchant acknowledges and agrees that it shall be solely responsible for limiting the associated value of a Gift Card to $2,000 per day and implementing any and all policies and procedures reasonably adapted to prevent the sale of prepaid access to funds of more than $10,000 to one individual per day and that failure to so limit such associated value and/or implement such policies and procedures may result in additional data collection, reporting, registration and other requirements being applicable to Merchant under the Rules. Xxxxxxxx further acknowledges and agrees that, other than Valutec’s obligation to provide an online reporting package in accordance with Section 2, Valutec shall have no obligation to provide any information or assistance to Merchant in connection with Merchant’s compliance with any Rule.
Bank Secrecy Act Compliance. To the best of its Knowledge, each Concord Entity is in compliance in all material respects with the provisions of the Bank Secrecy Act of 1970, as amended (the “Bank Secrecy Act”), and related anti-money laundering and anti-terrorist funding laws and regulations, including, but not limited to, those provisions of the Bank Secrecy Act that address suspicious activity reports and compliance programs, and the requirements of the Office of Foreign Assets Control (collectively, “BSA/AML Requirements”). To the best of its Knowledge, each Concord Entity has, to the extent required by BSA/AML Requirements, implemented a compliance program that adequately covers all BSA/AML Requirements, including, without limitation, the program elements as required by 12 C.F.R. §21.21. For purposes of this Section 5.24, “Knowledge” includes the the personal knowledge after due inquiry of each BSA officer and compliance officer of each Concord Entity, regardless of the title of such person, and the knowledge of any such persons obtained or which would have been obtained from a reasonable investigation.
Bank Secrecy Act Compliance. The First Xxxxxxxx Entities are in compliance in all material respects with the provisions of the Bank Secrecy Act of 1970, as amended (the “Bank Secrecy Act”), and all regulations promulgated thereunder including, but not limited to, those provisions that address suspicious activity reports and compliance programs, and all applicable requirements of the Office of Foreign Assets Control. Without limiting the foregoing, Target Bank has implemented a Bank Secrecy Act compliance program that adequately covers all of the required program elements as required by 12 C.F.R. §21.21.
Bank Secrecy Act Compliance. (1) Within sixty (60) days of the date of this Agreement, in response to the risks assessed as set forth in the Report of Examination, the Board shall develop, implement, and thereafter ensure Bank adherence to a written program of policies and procedures to provide for compliance with the Bank Secrecy Act (“BSA”), as amended (31 U.S.C. §§ 5311 et seq.), the regulations promulgated thereunder at 31 C.F.R. Part 1020, 12 C.F.R. Part 163.177, and for the appropriate identification and monitoring of transactions that pose greater than normal risk for compliance with the BSA.
(2) This program shall include, but not be limited to, the following:
(a) expanding the BSA risk assessment to include all high-risk customers, including those customers whose expected activity is currently unknown;
(b) establishing a process whereby the BSA Officer reports to relevant managers the status of employee training efforts throughout the year, and staff members or management who do not complete compliance training efforts are held accountable;
(c) ensuring information completed at account opening includes expected account behavior and performing customer due diligence information on older “grandfathered” accounts; and
(d) expanding enhanced due diligence procedures to consistently include a comparison of actual customer activity against expected activity.
(3) Upon adoption, a copy of this program shall be submitted to the Assistant Deputy Comptroller for review. In the event the Assistant Deputy Comptroller recommends changes to the program, the Board shall immediately incorporate those changes into the program.
Bank Secrecy Act Compliance. Cardinal is in compliance in all material respects with the provisions of the Bank Secrecy Act of 1970 (the “Bank Secrecy Act”), and all regulations promulgated thereunder including, but not limited to, those provisions of the Bank Secrecy Act that address suspicious activity reports and compliance programs. Cardinal has implemented a Bank Secrecy Act compliance program that adequately covers all of the required program elements as required by 12 C.F.R. §21.21.
Bank Secrecy Act Compliance. KBI is and has been in compliance in all material respects with the provisions of the Bank Secrecy Act, and all regulations promulgated thereunder including, but not limited to, those provisions of the Bank Secrecy Act that address suspicious activity reports and compliance programs. KBI has implemented a Bank Secrecy Act compliance program that adequately covers all of the required program elements as required by 12 C.F.R. § 21.21.
